Work at height is the most heavily scrutinised section of any RAMS, because falls from height remain the largest single cause of fatal injury to workers in Great Britain year after year in HSE's published statistics. Reviewers know it, inspectors know it, and a work at height RAMS gets read more carefully than anything else you submit — so the general approach in how to conduct a site-specific risk assessment has to be applied with more care here than anywhere.
Two things decide whether it holds up: whether it follows the statutory hierarchy honestly, and whether the rescue plan would actually work.
What counts as work at height
The Work at Height Regulations 2005 define it as work in any place where a person could fall a distance liable to cause personal injury — including below ground level, and including access and egress to a place of work. There is no two-metre threshold. Working from a hop-up next to an open riser shaft is work at height; so is working alongside an unprotected excavation.
The hierarchy your document must follow
Regulation 6 sets a sequence, and a RAMS that jumps to the bottom of it without addressing the top is the most common reason this section fails.
- Avoid work at height where it is reasonably practicable to do the work safely otherwise — assemble at ground level, use extendable tools, design out the access.
- Where it cannot be avoided, use work equipment or other measures to prevent a fall — a scaffold with a full guardrail, a MEWP, a tower with edge protection.
- Where the risk of a fall remains, use equipment or measures to minimise the distance and consequences — nets, soft landing systems, and only then personal fall arrest.
Collective protection comes before personal protection at every level: a guardrail protects everybody who walks past it, a harness protects only the person wearing it correctly. If your document reaches for harnesses first, expect it back. The general principle is the same one covered in the hierarchy of control, applied to a specific statutory duty.
The access equipment, described properly
Scaffolding
State the type and configuration, whether it is a TG20-compliant basic scaffold or a bespoke design requiring calculation, the design loading and what you intend to load it with, who erected it and under whose CISRS competence, and the inspection regime: before first use, at intervals not exceeding seven days, and after any event likely to have affected its strength or stability. Reference the scafftag or handover certificate. If the scaffold belongs to the principal contractor, say so and say who authorises alterations — unauthorised removal of a tie or a guardrail by another trade is a recurring cause of collapse.
Mobile access towers
Height, the erection method (3T or advance guardrail), PASMA competence, stabilisers or outriggers, the ground conditions the tower will stand on, the rule that it must not be moved with people or materials on it, and the maximum wind speed for use. Manufacturer's instructions should be on site.
MEWPs
Machine type and reason for selection, IPAF category and operator card, ground bearing capacity and any spreader plates, the exclusion zone below, and the harness and restraint lanyard arrangement for a boom-type platform — restraint to prevent ejection, not a fall arrest lanyard that permits a fall. Critically: the rescue arrangement for entrapment or a stranded platform, including who is trained in ground-level emergency lowering and where the controls are.
Ladders and stepladders
Ladders are legitimate for short-duration, low-risk work where a risk assessment shows other equipment is not justified — but the document must justify it rather than assume it. State the duration, the task, the three-points-of-contact rule, footing or tying arrangements, and the ground condition. "Use of ladders as required" with no justification is a finding.
Fragile surfaces
Regulation 9 imposes specific duties. Any work on or near a fragile surface — most roof lights, many older asbestos cement and fibre cement roofs, some liner panels — needs platforms, coverings or guardrails, plus prominent warning signage. Falls through fragile roofs kill people every year and this section must be explicit, not implied.
Dropped objects
The hazard that is missing from most work at height RAMS. Exclusion zones with physical demarcation and a person maintaining them, toe boards and brick guards, netting or debris sheeting, tool tethers where appropriate, and a controlled method for raising and lowering materials rather than throwing or hand-passing. Say who enforces the exclusion zone, because an unenforced barrier is decoration.
The rescue plan
Regulation 4 requires work at height to be properly planned, and planning includes planning for emergencies and rescue. This is the section most often reduced to "call the emergency services", which is not a plan.
Where fall arrest is used, a suspended casualty is a time-critical emergency: suspension in a harness restricts venous return and a conscious casualty can deteriorate quickly, so the plan must be measured in minutes, not in ambulance response times. It needs to state the rescue method and equipment, who is trained to carry it out and where they will be, how the casualty will be reached and lowered, how the alarm is raised, and how the casualty is treated and monitored afterwards. Rescue equipment must be on site and accessible, not in a van at another job.
The same applies to a MEWP: entrapment against a structure, or a machine failure at height, needs a named person who can operate the ground controls and a means of reaching the platform.
The rest of the section
- Weather limits: a stated maximum wind speed for towers, MEWPs and lifting, who measures it, and the trigger to stop work. Also ice, and the effect of rain on surfaces.
- Inspection records: pre-use checks by the user, and statutory inspections with dates and records available on site.
- Equipment examination: fall arrest equipment inspected before use and thoroughly examined at intervals, with records.
- Competence: PASMA, IPAF, CISRS and any harness use and inspection training, with card numbers and expiry dates.
- Public and other trades: protection for anyone below or passing, particularly on occupied or public-facing sites.
- Lone working: whether anyone will work at height alone, and if so how the alarm is raised.
The checks before you submit
Read the document as a reviewer will: is avoidance addressed before prevention, and prevention before arrest? Is there a rescue plan with a named person and equipment on site? Are dropped objects covered? Are the inspection intervals stated rather than assumed? Is every piece of access equipment matched to a competency card?
The first four are checks an automated pass runs on every document: a hazard with no control against it, and PPE offered as the sole control for a significant hazard, are both critical findings in a Valify report — see what critical means. The rescue plan is the one to check yourself. A tool reads what the document says; whether the rescue arrangements would work on this structure, with these people, is a judgement for your competent person.
This article is general guidance on UK construction documentation practice. It is not legal advice, a compliance certification or a substitute for review by your own qualified health and safety personnel, who remain responsible for deciding whether any particular document is adequate. See our disclaimer.